Mixture of legal identities: Case of the Dutch (1838) and the Serbian Civil Code (1844)

The paper aims to examine the differences and similarities between the Dutch Civil Code of 1838 and the Serbian Civil Code of 1844. Although the historical circumstances of the two countries, their legal culture and their legal systems at the time of codification were significantly different, the au...

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Main Author: Avramović Sima
Format: Article
Language:English
Published: University of Belgrade, Faculty of Law, Belgrade, Serbia 2018-01-01
Series:Anali Pravnog Fakulteta u Beogradu
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Online Access:https://scindeks-clanci.ceon.rs/data/pdf/0003-2565/2018/0003-25651804013A.pdf
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author Avramović Sima
author_facet Avramović Sima
author_sort Avramović Sima
collection DOAJ
description The paper aims to examine the differences and similarities between the Dutch Civil Code of 1838 and the Serbian Civil Code of 1844. Although the historical circumstances of the two countries, their legal culture and their legal systems at the time of codification were significantly different, the author points to some similarities between their private law codes. Based on that comparison he distinguishes a more general problem of early modern codifications in the 19th century, namely the issue of legal transfer's logic, causes and outcomes. Both in the cases of the Dutch and the Serbian codifications the predominant stereotype in literature are that they were more or less copies of the model codes (the French Code Civil of 1804 and the Austrian Civil Code of 1811, respectively). The author points out that only recently some diverse intonations started to appear on this matter, related to the two codifications. He stresses that in both cases legal borrowings were in many aspects inventive, innovative and influenced by a variety of other sources. The author based his conclusion on a comparative analysis of different legal identities present in the Dutch and Serbian codes. On that ground he revises the concept of mixed legal systems and suggests that mixture of legal identities should be more flexible, less demanding and open-ended notion.
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spelling doaj-art-795abef3bbd94226bc80a3b3ab37e2f62025-08-20T01:57:44ZengUniversity of Belgrade, Faculty of Law, Belgrade, SerbiaAnali Pravnog Fakulteta u Beogradu0003-25652406-26932018-01-01664133710.5937/AnaliPFB1804013A0003-25651804013AMixture of legal identities: Case of the Dutch (1838) and the Serbian Civil Code (1844)Avramović Sima0University of Belgrade, Faculty of Law, SerbiaThe paper aims to examine the differences and similarities between the Dutch Civil Code of 1838 and the Serbian Civil Code of 1844. Although the historical circumstances of the two countries, their legal culture and their legal systems at the time of codification were significantly different, the author points to some similarities between their private law codes. Based on that comparison he distinguishes a more general problem of early modern codifications in the 19th century, namely the issue of legal transfer's logic, causes and outcomes. Both in the cases of the Dutch and the Serbian codifications the predominant stereotype in literature are that they were more or less copies of the model codes (the French Code Civil of 1804 and the Austrian Civil Code of 1811, respectively). The author points out that only recently some diverse intonations started to appear on this matter, related to the two codifications. He stresses that in both cases legal borrowings were in many aspects inventive, innovative and influenced by a variety of other sources. The author based his conclusion on a comparative analysis of different legal identities present in the Dutch and Serbian codes. On that ground he revises the concept of mixed legal systems and suggests that mixture of legal identities should be more flexible, less demanding and open-ended notion.https://scindeks-clanci.ceon.rs/data/pdf/0003-2565/2018/0003-25651804013A.pdfcomparative legal traditionslegal transplantslegal transfermixed legal systemsprivate law codifications
spellingShingle Avramović Sima
Mixture of legal identities: Case of the Dutch (1838) and the Serbian Civil Code (1844)
Anali Pravnog Fakulteta u Beogradu
comparative legal traditions
legal transplants
legal transfer
mixed legal systems
private law codifications
title Mixture of legal identities: Case of the Dutch (1838) and the Serbian Civil Code (1844)
title_full Mixture of legal identities: Case of the Dutch (1838) and the Serbian Civil Code (1844)
title_fullStr Mixture of legal identities: Case of the Dutch (1838) and the Serbian Civil Code (1844)
title_full_unstemmed Mixture of legal identities: Case of the Dutch (1838) and the Serbian Civil Code (1844)
title_short Mixture of legal identities: Case of the Dutch (1838) and the Serbian Civil Code (1844)
title_sort mixture of legal identities case of the dutch 1838 and the serbian civil code 1844
topic comparative legal traditions
legal transplants
legal transfer
mixed legal systems
private law codifications
url https://scindeks-clanci.ceon.rs/data/pdf/0003-2565/2018/0003-25651804013A.pdf
work_keys_str_mv AT avramovicsima mixtureoflegalidentitiescaseofthedutch1838andtheserbiancivilcode1844